Mec Vannin, since its earliest days, has recognised the necessity of an
"environmentally friendly" approach to waste management. The necessity
is formed of three basic components:

1. It is ultimately far more expensive to import and throw away then to
reduce, reuse or recycle.

2. It is not physically possible to endure such a policy of disposal.

3. The indirect negative results of such a policy far outweigh its
benefits in terms of expedience and low direct cost.

Opponents of what are referred to as "environmentally friendly"
policies immediately cite cost and practicallity as an inhibitor. Such
people either have a vested economic interest in pursuing such a policy
or do not have a full appreciation of cause and effect.

The government in the Isle of Man recognised the harsh reality that
simple land-fill was impossible to sustain some twenty years ago.
Incineration was identified as a quick-fix alternative.

Mec Vannin opposes incineration as a bulk waste disposal option.

Since it was decided that incineration would form the primary method of
waste disposal in the Island, government policy has been drawn up so as
to give the appearance of a structured policy with incineration as a
final option. In reality, little appears to have been done to back this
up.

Reduction: In the 15+ years that incineration has been the objective of
the DLGE, no policies have been instituted to reduce the volume of the
waste stream to start with.

Re-use: In the same time span, there is no eveidence that any policies
have been instuted to encourage or force the re-use of materials.

Re-cycle: The general public has demonstrated its willingness to
cooperate with recycling initiatives such as bottle, paper and clothing
banks. This goodwill has all too often been ignored and undermined by
the DLGE which has, in the past, dumped segregated materials on the
excuse that it was uneconmic to recycle them.

A meeting with the previous minister confirmed that newspapers,
segregated so concientiously by the public, are being used to pack-out
the bulk required for incineration.

All these combine to confirm our position that the DLGE has not been
adhering to its own policies. Nor has the government operated
cohesively, most especially between the DLGE, Treasury and DTI, to
provide the structures necessary to make them work. Mec Vannin
submitted to government in the mid-1990s stating the requirement to do
this.

Such alternative waste disposal options that have been established are
on an ad-hoc basis, usually by private enterprise when there is a
market available.

This has been the complete reverse of how the process should have been
tackled.

The Treasury and DLGE have had over 15 years to introduce fiscal
measures to discourage waste at source. This could include
packaging tax, as suggested by Mec vannin in the mid 1990s. Taxes could
be levied on new materials when reusable ones are available. Fiscal
measure could be used to change both domestic and commercial purchasing
and disposal habits. this opportunity has not been taken.

Early measures should have been taken to encourage segretation of
re-usable and recyclable materials. contrary to the claims made in the
consultation paper, both the public and business sector have shown
great willingness to co-operate with such initiatives without the need
for "incentives". Naturally, commercial activities in particular will
be discouraged if they have to spend any time and expense in this but
if the means are provided, most will comply. Only after this is in
place, should negative incentives be considered.

The opportunity to create industry in the Island as part of the
recycling initiative have been largely ignored. Again, the Treasury,
DTI and DLGE have had 15 years in which to establish operations that
take recyclable waste and create useable materials for our own
consumption.

Card and paper can be readily recycled to produce packaging card and
mashe. Much of the wood ripped out and burnt / dumped could be
readily remachined and used were that to be economically preferable to
bying new timber. Thousands of tons of inert building material has gone
into landfill when it could have been segregated and "banked" to
provide a source of hardcore and infill material for construction
projects.

Composting is finally being looked at but this should have been
available from the start. Onchan Commissioners tried a pilot project in
the 1990s that was not succeesful. It failed because, in such an
isolated pilot scheme and without help from central government, it
proved simply too expensive as an ad-hoc project.

As one of the major sources of domestic waste, composting would have
had a huge impact on waste volume had it been introduced years ago.
Experiments in composting show that it is successful with most organic
materials when carried out correctly. This includes light plastic
materials and card.

We support kerbside segregation and collection of re-usable and
recyclable materials but the proposed costing structures are
contentious to say the least. The lack of clear direction in the DLGE
once more becomes clear. A central, all Island policy on how to manage
waste is essential if it is to be successful but the DLGE wants to dump
responsibility for implementation and costing on the Local Authorities.

Central governemnt must provide all facilities, available to all at a
uniform rate. The method of charging must be consistent or
there will be chaos.

In this, the "user / polluter pays" principle has been, at least in
part, misinterpreted. Government has allowed (even encouraged) a
society to develop that cannot avoid producing waste. Much of this
waste is imported. Who is the polluter? The person who consumes a food
item supplied in non-re-susable / recyclable packaging or the vendor
who supplies it in that form?

The document acknowledges our expressed concern that illegal dumping
will ensue if costs are prohibitive, despite having this concern
rejected by the previous minister.

If the domestic household is to be charged on a pro-rata basis for
waste, then the methods of measurement must be in place beforehand, not
later.

It is irrational to fix a price and then subsidise it as is happening
at the moment. Domestic users should be afforded a waste allowance
before charges are incurred. Commercial operations may require a
different structure as the nature of waste will differ from case to
case. In all instances, however, a prohibitively high cost of disposal
will result in illegal dumping and economic hardship for some, at least.

An affordable disposal cost should be identified and any disparity
between that cost and the actual cost of disposal be met through the
department's budget.

There should be no disparity between the cost of like for like types of
waste between domestic and commercial waste.

Only non-segregated, non re-usable / recyclable waste should incur the
pro-rata disposal charge in the domestic environment at least.

The incinerator is supposed to be a "last resort" method of dealing
with waste. The current practice of burning re-usable / recyclable
material to maintain a certain bulk should be discontinued, especially
as the operation is a net consumer of energy.

We are not entirely negative about the document, but have not had time
to properly study its implications: Only a month while Treasury has
also put out three consultative documents with a mere month and the
DHSS also have an entire draught bill with the same time for input.

If government departments genuinely want quality input from
consultation, it will have to learn to co-ordinate itself a little
better.

In summary, we feel that the DLGE has failed to adhere to its own
policies. It has failed to liase with other departments to produce an
effective, practical policy to aid in the implementation of the stated
policies and, while some of the proposals are moves in the right
direction, the department has worked completely in reverse.

The priority must be put heavily on reduction of waste at source and
shifting at least part of the cost of waste management onto those who
produce what will become waste at source, not merely economically
penalise those who are effectively forced to throw it away at the end
of the process.